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Deductions are Allocated and Apportioned in Classes Existing in Year Taken (AM 2022-001, 5/6/2022)
  • May 11
  • 1 min

Deductions are Allocated and Apportioned in Classes Existing in Year Taken (AM 2022-001, 5/6/2022)

Taxpayers argue that deferred compensation expense earned prior to the enactment of 250(b) Foreign Derived Intangible Income should not...
Additional Drafts of 2021 Schedules K2 and K3 Released
  • May 4, 2021
  • 1 min

Additional Drafts of 2021 Schedules K2 and K3 Released

Draft 2021 Schedules K2 and K3 Released (IR-2021-98; April 30, 2021) The IRS has released draft Schedules K-2 and K-3 for the Forms 1065,...
Final Regulations Issued on Sourcing Rules for Sales of Inventory Property (T.D. 9921)
  • Feb 16, 2021
  • 2 min

Final Regulations Issued on Sourcing Rules for Sales of Inventory Property (T.D. 9921)

The Sourcing Rules §861-865 The sourcing rules have an important purpose for US persons and non-US persons. Since a US person is taxed in...

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